Justia Wyoming Supreme Court Opinion Summaries

The dispute centers on a series of complex financial transactions involving a Wyoming family and their businesses, a local bank, and a commercial lender. The plaintiffs, including a married couple and their closely held LLC, entered into various loans and mortgages related to their commercial property and business operations. When financial difficulties arose—exacerbated by a downturn in the oil and gas industry—the parties restructured their debt, resulting in a 2017 mortgage and, after the operating company filed for bankruptcy, a 2019 settlement agreement. The plaintiffs later alleged that the bank and lender’s actions and omissions caused them to lose equity in both their home and commercial property, and the defendants counterclaimed for breach of the settlement agreement and sought attorney fees.The District Court of Natrona County dismissed or granted summary judgment for the bank and lender on all claims and counterclaims, finding the mortgage unambiguously secured two loans and the bank had no duty to release it after only one was repaid. It also concluded the plaintiffs could not establish justifiable reliance on any alleged misrepresentations, interpreted the settlement agreement as permitting (but not requiring) the lender to record the quitclaim deed after a sale period, and found no breach by the lender. The district court further ruled the plaintiffs breached the agreement by filing suit, thus entitling the bank and lender to attorney fees.On review, the Supreme Court of Wyoming affirmed the district court’s decisions dismissing the plaintiffs’ claims, holding the mortgage secured both loans and the bank acted within its rights. The Supreme Court, however, reversed the grant of summary judgment to the bank and lender on their counterclaims, finding that filing the lawsuit was not a breach of the settlement agreement or its implied covenant of good faith and fair dealing. Consequently, the award of attorney fees and costs to the bank and lender was also reversed. View "Adams v. ANB Bank" on Justia Law

The appellant, a former military service member, began suffering significant symptoms of multiple sclerosis shortly after receiving a second hepatitis A/B vaccine dose. Believing the vaccine caused or aggravated her condition, she sought compensation through the National Vaccine Injury Compensation Program. Dissatisfied with her first attorney’s handling of the case—specifically, the failure to include a claim for the earlier vaccine dose—she retained the appellee attorney in 2018 to address these concerns. The appellee refiled her petition, but ultimately did not include the earlier vaccine. While her compensation case was still pending, the appellant terminated the appellee’s representation and proceeded pro se.Afterward, the appellant sued the appellee and his law firm in the District Court of Laramie County for legal malpractice, alleging negligence and negligent infliction of emotional distress. The district court dismissed the emotional distress claim but allowed the malpractice claim to proceed. The court set a deadline for expert witness designation, which the appellant missed. She later moved to extend this and other deadlines, citing her brother’s injury and subsequent passing, as well as difficulties finding an expert while representing herself. The district court found she had not shown good cause or excusable neglect and denied her motions. The appellee then moved for summary judgment, arguing that the appellant’s failure to designate an expert was fatal to her malpractice claim.Upon review, the Supreme Court of Wyoming found that the district court did not abuse its discretion in denying deadline extensions, as the appellant failed to demonstrate good cause or excusable neglect. The Court also held that expert testimony was required to establish the standard of care, breach, and causation in a legal malpractice case, and summary judgment was proper because the appellant did not produce such testimony. The Court affirmed the district court’s decision. View "Williams v. Gage" on Justia Law

A high school assistant principal was charged with second-degree sexual assault after engaging in a sexual relationship with a student at the same school. The events began with daily conversations and gifts, followed by increasingly personal text messages. On one occasion, after exchanging messages about meeting up, the student—who was of age but intoxicated—went to the assistant principal’s home, where they engaged in sexual activity. Weeks later, a friend of the student discovered text messages revealing the relationship and reported it to school officials, who contacted law enforcement. After a brief investigation, the assistant principal was arrested and charged under a statute prohibiting sexual contact between school employees and students when the employee is more than four years older.At trial in the District Court of Sheridan County, the State successfully moved to exclude evidence of alleged post-graduation contact between the student and the defendant, specifically claims that the student attended the same gym as the defendant after the school year. The defense argued this evidence could be relevant for impeachment if the student claimed fear or coercion, but the court ruled such evidence irrelevant unless the student’s state of mind was placed at issue, which did not occur at trial. The jury found the defendant guilty, and he was sentenced to prison.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion by excluding the gym contact evidence and whether admitting brief victim impact testimony constituted plain error. The Supreme Court held that exclusion of the gym evidence was not an abuse of discretion because it was irrelevant to the charged offense, and that any error in admitting victim impact testimony did not result in material prejudice given the overwhelming evidence of guilt. The conviction was affirmed. View "Meyer v. The State of Wyoming" on Justia Law

The case concerns a defendant who, along with a co-conspirator, engaged in a scheme to defraud an elderly victim by misrepresenting their identities and gaining her trust. Over time, the victim was persuaded to provide money through cash, credit card charges, and loans, purportedly to fund a business venture, with promises of profit sharing that never materialized. The co-conspirator also convinced the victim to transfer ownership of her home, claiming it was necessary for maintenance and financial assistance. After discovering unauthorized credit card activity and missing property, the victim reported the matter to authorities, leading to an investigation that uncovered widespread unauthorized transactions and no evidence of a legitimate business.The State of Wyoming charged the defendant with felony theft and conspiracy to commit theft. Pursuant to a plea agreement, the defendant entered a no contest plea to conspiracy, with the theft charge dismissed and restitution to be determined at a hearing in the District Court of Laramie County. At the restitution hearing, the State presented evidence of unauthorized credit card charges and cash advances totaling $92,722.79. The defendant argued that certain credit card charges, particularly those allegedly used for concrete improvements to the victim’s property, should be deducted from restitution because the victim benefited from those expenditures. The district court found insufficient evidence to identify any charges as being for the concrete work or to substantiate the value of such benefit, and therefore declined to deduct those amounts from the restitution award.On appeal, the Supreme Court of the State of Wyoming reviewed whether the district court abused its discretion in denying the requested deduction. The Supreme Court held that the district court did not abuse its discretion, finding no clear evidence that the restitution amount included charges for concrete work that benefited the victim. The order awarding restitution in the amount of $92,722.79 was affirmed. View "Baier v. State" on Justia Law

A husband and wife married in 1989 and separated in 2023. They had a long marriage, shared two adult daughters, and owned a marital home on twenty-six acres near Casper, Wyoming, as well as other real and personal property, including an undeveloped plot in Alaska. The marital estate included several vehicles, campers, tractors, snowmobiles, retirement and investment accounts, and pensions. The husband filed for divorce, seeking dissolution of the marriage and division of property. At trial, the main disputes involved the valuation of the marital home and the wife’s pension accounts. Both parties presented expert testimony on these values, with differing appraisals and methods.The District Court of Natrona County held a bench trial and divided the marital property, awarding the husband the marital home, the Alaska property, and most of the vehicles and equipment. The wife was awarded her pensions, a smaller share of personal property, and an $850,000 equalization payment from the husband, to be paid within ninety days. Neither party requested special findings of fact regarding the valuations. The husband appealed, arguing that the district court abused its discretion by accepting higher valuations for the marital home and lower valuations for the wife’s pensions, resulting in an excessive equalization payment.The Supreme Court of Wyoming reviewed the case for abuse of discretion. It held that, because neither party requested special findings of fact, it must presume the district court made all factual findings necessary to support its judgment. The Supreme Court concluded that sufficient evidence supported the district court’s valuation choices, that the distribution reflected consideration of the statutory factors, and that the overall property division, including the equalization payment, was not so unfair as to shock the conscience of the court. The court affirmed the district court’s decree. View "Allen v. Allen" on Justia Law

A 15-year-old boy shot and killed his former girlfriend, a 17-year-old, after sending her harassing and threatening messages. The confrontation occurred at a park following an exchange with the victim’s cousin, which escalated into a plan to fight. The defendant brought his mother’s handgun to the scene and, during the confrontation, shot the victim in the face as she approached him. He was apprehended shortly after the shooting and confessed to law enforcement.The State originally charged the defendant with first-degree murder and misdemeanor stalking. Pursuant to a plea agreement, he pled guilty to second-degree murder and stalking. At sentencing, the prosecutor and defense agreed that an individualized hearing was appropriate, given the defendant’s juvenile status. The prosecution recommended a sentence of 44 to 75 years for the murder conviction, referencing Wyoming’s Bear Cloud line of cases and statutory limits for juvenile offenders. The defense argued that, under Wyoming law and constitutional principles, the maximum allowable sentence for a juvenile convicted of homicide should be 22.5 years to life, or at most a minimum term not exceeding 43 years. The District Court of Natrona County sentenced the defendant to 42 to 75 years for second-degree murder and time served for stalking.On appeal, the Supreme Court of the State of Wyoming reviewed whether (1) Wyoming’s juvenile parole eligibility statute applied, (2) the sentence exceeded statutory limits, and (3) the sentence violated the Wyoming Constitution’s prohibition on cruel or unusual punishment. The Court held that the parole eligibility statute applied only to life sentences, not to terms of years. The sentence fell within statutory limits for second-degree murder. Finally, the Court found the sentence was not “unusual” under the state constitution because there was no consensus among legislatures or courts that such a sentence for a juvenile was unlawful. The Supreme Court affirmed the district court’s judgment. View "Castaner v. The State of Wyoming" on Justia Law

The case involved allegations that a man sexually abused his stepdaughter, JB, when she was a child and later sexually assaulted his biological daughter, FO, when she was a teenager. After JB disclosed the abuse to her probation officer, both she and FO were interviewed by police and provided accounts implicating the defendant in two separate incidents of sexual intrusion. The State charged the defendant with two counts of first-degree sexual abuse of a minor.During trial proceedings in the District Court of Campbell County, the court granted the defendant’s motion to sequester witnesses. However, it was discovered that JB and FO overheard brief portions of a livestream of the trial while waiting to testify, in violation of the sequestration order. The district court questioned the witnesses outside the jury's presence, found no intentional or prejudicial violation, and allowed limited cross-examination on what they overheard, but did not permit questioning about their violation of a court order. The defendant also moved for mistrials based on allegedly improper testimony referencing uncharged conduct under Wyoming Rule of Evidence 404(b), but the court either struck the testimony and instructed the jury to disregard it or found the testimony did not reference uncharged acts, and denied the motions.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in limiting the scope of cross-examination and denying mistrials, and whether the defendant’s Confrontation Clause rights were violated. The court held that the district court acted within its discretion, as the violations of the sequestration order were minimal and non-prejudicial, and the limitations on cross-examination did not infringe on the defendant’s confrontation rights. The court also found no abuse of discretion in denying the motions for mistrial and found no cumulative error. The Supreme Court of Wyoming affirmed the convictions. View "O'Dell v. The State of Wyoming" on Justia Law

The case concerns a shooting incident that occurred late at night in Douglas, Wyoming, when the defendant called 911 to report he had shot his cousin, believing the cousin was breaking into his home. Investigation revealed that the cousin was an invited guest, and the defendant gave inconsistent accounts of the events leading up to the shooting, including claims of memory loss and possible intoxication. Both the defendant and the victim had consumed alcohol and the defendant had used THC. The defendant was charged with first-degree murder and pursued defenses including not guilty by reason of mental illness and self-defense. Psychiatric evaluations offered differing opinions on his mental state, one attributing his actions to a PTSD flashback and the other finding his intoxication contributed to his conduct.In the District Court of Converse County, the defendant moved to dismiss the charges, asserting immunity under a Wyoming self-defense statute. The district court excluded testimony from one of the psychiatric experts, finding it irrelevant under the governing statutes, and further determined that the defendant failed to present competent evidence sufficient to establish a prima facie case for self-defense immunity. The case proceeded to a jury trial, where the defendant was convicted of second-degree murder and sentenced accordingly.Upon appeal, the Supreme Court of the State of Wyoming affirmed the district court’s decisions. It held that the lower court properly excluded the psychiatric testimony as irrelevant to the self-defense immunity issue. The Supreme Court found the defendant failed to present admissible, competent evidence to support a prima facie self-defense claim. It declined to review the jury instruction challenge due to invited error, as the defendant proposed the instruction in question. Finally, the Supreme Court concluded that sufficient evidence supported the conviction for second-degree murder and affirmed the judgment. View "Helms v. The State of Wyoming" on Justia Law

A child born in 2014, RTT, was placed under the co-guardianship of his maternal grandfather, James Serfoss, III, and Mr. Serfoss’s domestic partner, Leslie M. Salmon, beginning in 2016. The two petitioners are not married. In 2025, RTT’s biological father, Tyler Thomas, sought to terminate the guardianship. In response, Serfoss and Salmon jointly counterclaimed, seeking to adopt RTT. The child’s biological mother consented to the adoption, but the biological father did not.Following the joint adoption counterclaim, Mr. Thomas moved to dismiss, arguing that Wyoming law does not permit two unmarried individuals to jointly petition for adoption. The District Court of Converse County certified the legal question to the Supreme Court of Wyoming, asking whether Wyo. Stat. Ann. § 1-22-104(b) allows for a joint adoption petition by two unmarried individuals.The Supreme Court of Wyoming, reviewing the certified question de novo, held that Wyo. Stat. Ann. § 1-22-104(b) does not permit two unmarried individuals to file a joint petition to adopt a minor child. The statute expressly allows joint petitions only for married couples and does not authorize joint petitions by multiple unmarried individuals. The court emphasized that while each unmarried adult may separately petition for adoption, they cannot file jointly; the district court may, however, consolidate separate petitions for consideration. The court declined to read into the statute any broader authority or to interpret legislative silence as permitting joint petitions by unmarried individuals. The Supreme Court’s answer to the certified question was therefore “no.” View "In the Matter of the Guardianship Of: RTT" on Justia Law

The appellant in this case was a member of two limited liability companies, holding approximately a 33% interest. After disputes arose concerning the operation of the LLCs, the appellant initiated litigation seeking dissolution and other relief. Subsequently, he was expelled as a member. The LLCs’ operating agreement required immediate compensation for expelled members’ interests, but the appellant was not paid. While the case was ongoing, the district court enjoined the LLCs from harming the appellant’s interests and appointed a special master to value those interests. Despite the injunction, the appellant’s membership interests were assigned and sold to a third party without his knowledge. The appellant amended his complaint to assert conversion and defamation claims.A jury in the District Court of Park County found for the appellant, awarding $1,784,640 for conversion and $75,000 for defamation per se. Defendants moved post-judgment under Wyoming Rules of Civil Procedure 50(b), 59, and 60, arguing the conversion damages should not exceed the special master’s valuation and that defamation damages lacked evidentiary support. The district court initially denied the Rule 50(b) motion, affirming the jury’s findings. Later, under Rule 60(b), the court reduced conversion damages to $293,017 (the special master’s value) and defamation damages to $500, citing the appellant’s rightful expulsion and lack of proof of reputational harm or economic loss.The Supreme Court of Wyoming reviewed the district court’s reductions. It held that the appellant retained a property interest in the LLCs after expulsion until compensated, and the jury’s conversion award was proper based on fair market value at the time of conversion. For defamation per se, the Court clarified that Wyoming law allows presumed damages above nominal amounts, and sufficient evidence supported the jury’s $75,000 award. The Supreme Court reversed the district court’s reductions and reinstated the original jury awards. View "Mccall v. Best of the West Productions, LLC" on Justia Law